May
16,
2003
Greg
H.
Guinther
Senior
Advisor
Ethyl
Corporation
Ethyl
Petroleum
Additives,
Inc.
P.
O.
Box
2158
Richmond,
VA
23218­
2158
Dear
Mr.
Guinther,

On
May
2,
2003,
you
submitted
to
Joe
Sopata
of
my
staff
a
request
for
an
amendment
to
the
study
protocol
entitled,
"
Fleet
Testing
and
Vehicle
Service
Protocol
for
Ethyl
Corporation's
Alternative
Tier
2
Emission
Characterization
Program".
As
you
know,
the
MMT
Alternative
Tier
2
Health
Effects
Testing
Requirements
require
Agency
approval
of
amendments
to
a
previously
approved
protocol.
This
study
protocol
was
approved
by
the
Agency
on
December
19,
2002.

With
this
amendment,
Ethyl
is
proposing
a
change
in
the
particulate
filter
and
handling
protocol,
which
addresses
the
way
particulate
filters
are
packaged
for
shipment
from
Southwest
Research
Institute
(
SwRI)
to
Lawrence
Livermore
National
Laboratory
(
LLNL).
According
to
your
letter
and
subsequent
telephone
conversations
with
Joe
Sopata
of
my
staff,
the
original
filter
packaging
and
handling
protocol
is
overly
complicated
and
unnecessary,
and
if
Ethyl
were
required
to
adhere
to
the
specified
particulate
filter
packaging
and
handling
protocol,
a
significant
delay
in
the
test
program
would
occur.
You
proposed
in
your
amendment
request
to
use
the
same
particulate
filter
packaging
and
handling
protocol
used
in
prior
MMT
speciation
programs.
This
prior
protocol
uses
a
procedure
where
a
particulate
filter
is
placed
in
a
plastic
petri
dish
which
is
sealed
with
tape
and
then
the
petri
dish
is
heat­
sealed
in
a
Tedlar
bag
with
a
specified
minimum
thickness.
We
agree
that
the
packaging
and
handling
protocol
used
in
previous
MMT
speciation
programs
is
sufficient
to
ensure
that
the
integrity
of
the
particulate
filter
is
maintained
during
shipment
from
SwRI
to
LLNL.
Therefore,
EPA
is
approving
your
request
for
this
amendment.
­
2­

If
you
have
any
questions,
please
contact
Joe
Sopata
of
my
staff
at
(
202)
564­
9034.

Sincerely,

/
s/

Suzanne
Rudzinski
Director
Transportation
and
Regional
Programs
Division
cc:
Monica
Alvarez,
ORD/
OSP
Tim
Backstrom,
OGC
Kevin
Fast,
Hunton
&
Williams
